1 

Evaluation of Enforcement of the Mexican Ban on 

Feeding Ruminant Proteins to Ruminants 

July 2009 

Summary 

The U.S. Department of Agriculture’s (USDA) Animal and Plant Health Inspection Service 

(APHIS) is proposing to amend its regulations related to bovine spongiform encephalopathy 

(BSE) to align more closely with recommendations of the World Organization for Animal 

Health (OIE). Under these regulations, APHIS must determine the date of effective 

enforcement of a ruminant-to-ruminant feed ban for any controlled-risk country that wishes 

to export live cattle to the United States; live cattle exported from a controlled-risk country 

must have been born after this date. APHIS evaluated information submitted by Mexico and 

conducted a site visit and determined that the date of an effectively enforced feed ban for 

Mexico is November 30, 2007. 

I. Background 

APHIS currently prohibits or restricts the importation of live ruminants and ruminant 

products for BSE based on regulations in title 9 of the Code of Federal Regulations (CFR) 

§§ 94.18(a)(1), (a)(2), and (a)(3). APHIS allows the importation of such commodities from 

countries not listed in those sections (assuming no other restrictions due to other diseases are 

in place) because a risk from BSE is not evident. 

APHIS is proposing to amend the regulations by more closely aligning them with the 2009 

recommendations of the OIE – i.e., BSE code chapter. These changes would apply to the 

regulations for bovines (cattle and bison of the species Bos indicus, Bos taurus, and Bison 

bison) and bovine products and byproducts. While enhancing international harmonization, 

these updates do not reflect a change in our level of protection of U.S. livestock from BSE. 

The proposed BSE regulations align with OIE’s Terrestrial Animal Health Code Chapter 

11.6 [1] by (1) adopting the categories and criteria for classification of the BSE risk status of 

exporting countries, and (2) using those categories to determine appropriate import policies. 

In addition, APHIS is proposing regulatory changes to recognize the BSE risk status of 

countries that have been evaluated and classified by OIE. 

Under current regulations, live bovines are eligible for importation from Mexico if the 

conditions in 9 CFR §§ 93.405(a)(3), 93.406, 93.427, and related sections are met. Briefly, 

these conditions specify that live ruminants meet screwworm, tick, tuberculosis, and 

brucellosis requirements. In May 2008, the OIE classified Mexico as a BSE controlled-risk 

region (like the United States and Canada). Thus, under the new regulations that APHIS is 

proposing, live bovines from Mexico would be subject to additional import requirements for 

BSE. Consistent with OIE recommendations, the importation of live bovines from any BSE 

controlled-risk region, including Mexico, would be limited to those born after the date of 

effective enforcement of a ruminant-to-ruminant feed ban in the exporting region. 
2 

In determining that a country has controlled-risk status for BSE, the OIE concludes that the 

country has an effectively enforced feed ban in place. However, the OIE does not determine 

the date on which the feed ban was effectively enforced. That task falls to the importing 

country. To determine this date for Mexico, a team of experts from APHIS and the 

Department of Health and Human Services’ Food and Drug Administration (FDA) evaluated 

information provided by Mexico’s Ministry of Agriculture, Livestock, Rural Development, 

Fisheries, and Food (Secretaría de Agricultura, Ganadería, Desarrollo Rural, Pesca y 

Alimentación or SAGARPA), including the dossier on BSE that Mexico submitted to the 

OIE in December 2007. The team gathered additional evidence during a site visit conducted 

in August 2008, during which it directly evaluated Mexico’s feed program as it relates to 

BSE. 

II. Mexico’s OIE Status for BSE 

In December 2007, Mexico submitted to the OIE a dossier containing BSE information to 

support an overall BSE evaluation and to obtain a BSE risk classification [2]. The 

information in the dossier was evaluated by internationally recognized BSE experts. On May 

27, 2008, the International Committee of the OIE adopted Resolution XXI [3] recognizing 

Mexico as having a controlled BSE risk in accordance with criteria provided in Chapter 11.6 

of the Terrestrial Animal Health Code. 

According to the OIE, commodities from counties with controlled BSE risk designation pose 

a controlled risk of transmitting the BSE agent when commodity-specific risk mitigation 

measures are met. In the case of live bovines, the primary mitigation is that the animal must 

be born after the date from which a ban on feeding meat-and-bone meal (MBM) and greaves 

derived from ruminants was effectively enforced in that region. This requirement mitigates 

the likelihood that imported bovines were exposed to the BSE agent in a region that had or 

may have had circulating infectivity. 

In granting Mexico BSE controlled-risk status, the OIE determined that Mexico has 

conducted a risk assessment sufficient to meet OIE criteria for identifying the historical and 

existing BSE risk factors in the region, and: 

(1) Has demonstrated that appropriate mitigations are being taken to manage all 

identified risks, but has not taken every mitigation measure for the length of time that 

would be necessary to qualify as a BSE negligible-risk region (7 or 8 years, 

depending on the mitigation measure); 

(2) Has demonstrated BSE surveillance according to BSE risk classification standards 

and meets the following conditions: 

 There has been no case of BSE reported in the region, and: 

 The following conditions have been met and continue to be met, but not for at 

least the past 7 years: 

a. The region has conducted an ongoing awareness program for veterinarians, 

farmers, and workers involved in transportation, marketing, and slaughter of 

bovines to encourage reporting of all bovines showing clinical signs that could 

be indicative of BSE; 
3 

b. The region has required notification and investigation of all bovines showing 

clinical signs consistent with BSE; 

c. The region has carried out the examination, in accordance with internationally 

accepted diagnostic tests and procedures and in approved laboratories, of 

brain or other tissues collected as part of the required surveillance and 

monitoring system; and 

d. The feeding to ruminants of MBM and greaves derived from ruminants is 

prohibited and effectively enforced in the region, but it cannot be 

demonstrated through an appropriate level of control and audit that the 

prohibited materials have not been fed to ruminants for at least the past 8 

years. 

In its review of Mexico’s dossier, the OIE ad hoc committee concluded that although Mexico 

qualified as a controlled risk country, the risk of recycling and release of the BSE agent is 

considered to be negligible because specified risk materials1

 (SRMs) are marketed profitably 

in Mexico exclusively for human consumption. This conclusion is based on data submitted 

by Mexico which states that brain and spinal cord from 100 percent of slaughtered cattle that 

meet suitability characteristics are used for human consumption and therefore are not 

available to be rendered for use in animal feed. Moreover, a review of Mexico’s import 

history does not indicate a high likelihood of release of infectivity in animals or commodities 

imported from trading partners. 

 

III. Mexico’s Feed Ban 

A. Legal Authority 

The overarching law concerning animal health in Mexico is the Federal Law of Animal 

Health. Article 4 of this law gives SAGARPA the authority to promote, encourage, organize, 

supervise, coordinate, and execute all types of activities pertaining to animal health in which 

different organizations and agencies of the municipal, State, and Federal governments, as 

well as people with a legal interest, can participate. 

 

1. Federal Veterinary Authority

SAGARPA is the Federal department within the government of Mexico responsible for 

regulating the agriculture and livestock sectors. It is considered equivalent to the USDA. 

SAGARPA has a delegation (office) in each of the 32 States of Mexico and one in the 

Lagunera Region2

. 

Within SAGARPA, the National Service of Health, Safety, and Quality Agrofood (Servicio 

Nacional de Sanidad, Inocuidad y Calidad Agroalimentaria or SENASICA) is equivalent to 

APHIS. SENASICA is divided into several general divisions (figure 1), three of which are 

 

1

 OIE defines specified risk materials as brain, eyes, and spinal cord. 2

 The Lagunera Region consists of five municipalities of the State of Coahuila and ten municipalities of the 

State of Durango. 
4 

directly focused on animal health: the Animal Health General Directorate (Direccion General 

de Salud Animal or DGSA), the Animal and Plant Health Inspection Service General 

Directorate (Direccion General de Inspeccion Fitozoosanitaria or DGIF), and the Agrofood 

Safety and Quality Control General Directorate (Direccion General de Inocuidad y Calidad 

Agroalimentaria or DGICA). 

Figure 1. Functional organization of SAGARPA 

The DGSA is headed by the Chief Veterinary Officer of Mexico. Within DGSA, the 

Directorate of Import, Export, Animal, and Animal Products Services and Certification 

(Dirección de Importación, Exportación, Servicios y Certificación Pecuaria or DIESCP) is 

responsible for the following: 

 Issuing import and export permits for animals and animal products 

 Registration and regulation of veterinary products (chemical, pharmaceutical, 

biological and feed products) 

 Approval of animal disease diagnostic tests and product quality control laboratories; 

accreditation of veterinarians in certain disciplines (laboratory diagnostics; 

ruminant, poultry, and swine veterinary practice) 

 Animal and animal product movement; slaughterhouses 

 Issuing health certificates necessary for movement of animals and/or animal 

products within Mexico 
5 

The DIESCP is divided into two subdirectorates: the Subdirectorate of Imports and Exports 

and the Subdirectorate of Approval, Certification, Registries, and Services (SCRS). The latter 

is responsible for the evaluation of compliance with the ruminant feed ban. The SCRS is 

further divided into three departments: (1) the Department of Regulation and Control of 

Veterinary Products, Units, and Organisms; (2) the Department of Regulation and 

Registration of Veterinary Products; and (3) the Department of Regulation of Establishments. 

2. State Animal Health Infrastructure

SAGARPA’s 33 State delegations (offices) manage the enforcement of Federal regulations 

and animal health activities at the field level, such as local prevention and control measures, 

census information, eradication, emergency actions, sampling, premises identification, 

movement controls, and recordkeeping. Each State delegation is headed by a State delegate 

who has an animal and plant subdelegate. 

In Mexico, much of the field work for SAGARPA’s animal health activities is provided 

through each State’s Committee for the Promotion and Protection of Animal Production 

(Comité Estatal de Fomento y Protección Pecuaria or CFPP), which receives funding from 

the State government, the livestock industries in the State, and the SAGARPA State 

Delegation. Each of these parties contributes a third of the budget required for supporting the 

yearly sanitary activities. 

The annual budget and program of activities of the CFPP is approved by SAGARPA. The 

CFPP has a President who is selected from one of the livestock industries of that State 

(bovine, porcine, poultry), a Federal Executive Assistant who is the ranking Federal 

SAGARPA official (State delegate), and a State Executive Assistant who is designated by the 

State government. The CFPP supports all of SAGARPA’s animal health activities through 

the hiring of professionals who will take samples, conduct censuses of animal populations, 

and inspect at control check points for movement of animals and animal products. CFPP 

reports its activities to the SAGARPA delegation. 

B. Mexican Feed Regulations 

The Official Standards of Mexico (Normas Oficiales Mexicanas or NOMs) are the 

regulations governing animal health activities. The mandatory participation of producers in 

animal health is based on these NOMs. The NOMs regarding feed and implementation of the 

feed ban are the following: 

NOM-012-ZOO-1993 (NOM-012) 

NOM-025-ZOO-1995 (NOM-025) 

NOM-026-ZOO-1994 (NOM-026) 

NOM-060-ZOO-1999 (NOM-060) 

NOM-061-ZOO-1999 (NOM-061) 

NOM 012, NOM 025, and NOM 026 established specifications for the production and 

quality control of chemical, pharmacological, biological, and nutritional products for use in 
6 

or consumption by animals, as well as the minimum infrastructure specifications for 

establishments producing nutritional animal products. 

NOM 061, published in October 2000, prohibited the use of ruminant-origin MBM in feed 

for ruminant animals. In addition, this regulation contained a number of other provisions, 

such as requirements for verifying guaranteed analyses of feeds and for statements on 

ingredient labels. 

NOM 060, published in June 2001, expanded BSE-related feed protections by placing new 

requirements on rendering operations. NOM 060 specified that rendering plants must 

establish certain time, temperature, and humidity standards for processing; maintain receipt, 

processing, and distribution records; and identify themselves as either type 1 renderers ( who 

handle mainly materials containing nonruminant tissues as well as hides and ruminant 

byproducts obtained from tanneries) or type 2 renderers (who handle ruminant materials 

containing ruminant tissues )The regulation prohibited feeding ruminants with ruminantorigin MBM and required that type 1 rendering plants must have control procedures in place. 

C. Feed Ban Oversight 

The Animal and Plant Health Federal Law of 1974 (published in December 1974) instructed 

SAGARPA to register all the Mexican companies that manufactured and commercialized 

biologics, pharmaceuticals, and feed products for animal use. The law and additional related 

regulations (Reglamento published in June 1978) also mandated the registration, licensing, 

and compliance requirements for the final products. Additionally, the law required that most 

of the regulatory oversight of the animal feed industries was to be handled by a SAGARPAcertified veterinarian that every firm must employ as a consultant for the annual renewal of 

company registration and product licenses. In 1993, the Federal Law was modified by 

including additional requirements and mandated that all official requirements were 

authorized through the NOM, such as the following: 

 NOM 012: Regulates final products 

 NOM 025: Regulates producers and commercial companies that manufactured 

pharmaceutical and biological products 

 NOM 026: Regulates producers and commercial companies of feed products 

NOMs 012, 025, and 026 required that each company hire an approved veterinarian (certified 

by SAGARPA) to handle the regulatory oversight of the sanitary activities, including visits 

for verification. The registration renewal for each facility included an official site visit by 

SAGARPA’s delegations in the Mexican States. In addition, the Animal and Plant Health 

Federal Law was modified to include a new Mexican Accreditation Body (Entidad Mexicana 

de Acreditacion or EMA) to provide support for the verification and certification processes. 

In 1996, due to the increasing number of companies registered and products licensed, new 

controls were implemented. Accredited veterinarians were authorized by SAGARPA to 

perform verification activities on behalf of SAGARPA, in lieu of official personnel. 

Companies had only to present a letter to SAGARPA from an accredited veterinarian 

indicating compliance with sanitary requirements. 
7 

Upon publication of BSE-related feed regulations NOM 061 in 2000 and NOM 060 in 2001, 

the verification unit veterinarians became responsible for bringing feed mills and rendering 

plants into compliance with these regulations. The Department of Regulation and Control of 

Products and Companies (DRPC) became responsible for registering and controlling the 

rendering plants that manufacture meals of animal origin. 

In 2003, the DRPC implemented an inspection program for all rendering plants to check for 

compliance with NOM 060. In the same year, the Mexican Association of Rendering Plants 

provided support to the process by providing the DRPC with a list of operational rendering 

plants. 

SAGARPA sent official letters to the rendering plants informing them of the need to comply 

with NOM 060 [4] and organized a workshop to educate veterinarians about the importance 

of the feed ban regulation and the procedure for verifying that feed manufacturers comply 

with the regulation. By November 2003, the assignments regarding feed controls were 

prepared and sent to the States. In July and September 2004, SAGARPA State Delegations 

started verifying the newly registered rendering plants. That year, a total of 13 rendering 

plants were registered in compliance with NOM 060. Three of those were classified as type 1 

plants and ten were classified as type 2 plants. 

In 2005, SAGARPA again sent official letters to the State Delegates asking for their support 

to find rendering plants that had not yet reported their operation and classification or that had 

not renewed their annual license. That year, 12 new rendering plants were registered, 1 as 

type 1 and 11 as type 2. Additionally, the 13 plants registered in 2004 were revisited to renew 

their license, bringing the total to 25 licensed rendering plants. Since 2005, the list of newly 

licensed and renewed rendering plants has been published and updated monthly on 

SENASICA’s Web site [5]. 

During 2006, SAGARPA registered a total of 11 new rendering plants; 5 of them were 

classified as type 1 and 6 as type 2, bringing the number of verified rendering plants to 36 by 

the end of 2006. The same year, SAGARPA requested that the EMA provide support for the 

annual verification of the rendering companies, and by the end of 2007 EMA verified 100 

percent of the rendering companies. These verifications were independent of those done by 

SAGARPA. 

In 2007, the structure of the DIESCP was modified and a new subdirectorate was created: the 

Subdirectorate of Approval, Certification, and Registration Services (SCRS). Within the 

SCRS, the DRPC was divided into three Departments: (1) the Department of Regulation and 

Control of Veterinary Products, Units and Organisms; (2) the Department of Regulation and 

Registration of Veterinary Products; and (3) the Department of Regulation of Establishments. 

The activities of the Department of Regulation of Establishments include the following: 

 Registration of companies that manufacture and/or commercialize biologic, 

pharmaceutical, and feed products according to NOM 025 and NOM 026 

 Coordination of the verification of the establishment inspection program 
8 

 Evaluation of compliance with a ruminant feed ban (NOM 061 and NOM 060) 

 Verification of compliance with NOM 061 and NOM 060 label requirements. 

According to SAGARPA officials, this reorganization greatly enhanced the Department’s 

contact with various elements of the ruminant livestock and feed industries and improved 

SAGARPA’s ability to ensure compliance with the feed ban regulations that are in place. 

During 2007, SAGARPA registered a total of 16 new rendering plants, 7 of which were 

classified as type 1 and 9 as type 2. At the end of 2007, a total of 52 plants were verified. 

SAGARPA trained new veterinary officials to conduct verifications and collect the 

documentation needed to complete Mexico’s OIE dossier. 

In 2008, SAGARPA registered three type 1 and three type 2 rendering plants. At that time, it 

also started identifying companies that were no longer in operation. As of October 30, 2008, 

65 rendering plants were registered and in operation, 20 of them type 1 and 45 type 2. 

D. Enforcement and Compliance 

SAGARPA and other recognized entities, such as third-party groups (referred to as 

Authorized Specialists and Verification Units certified by EMA), are authorized by the 

Federal Law of Animal Health to perform the verification of feed mills. However, only 

SAGARPA’s Department of Regulation of Establishments is authorized to conduct 

verification audits at rendering plants. SAGARPA enforces the feed ban at rendering plants 

and feed mills as follows: 

1. Rendering plants 

Feed ban enforcement became an increasing priority for SAGARPA in 2003 after BSE cases 

were reported in Canada and the United States. Beginning in 2004, SAGARPA began 

registering individual rendering plants. As part of the process, the agency established a 

verification program for Mexican rendering plants to further strengthen oversight and 

enforcement of the NOMs. SAGARPA’s Department of Regulation of Establishments 

coordinated the verification program to ensure that each firm complies with NOM 061 and 

NOM 060. Each year, the rendering plants must renew their registration and must also be 

included in the list of registered rendering plants, which is published on SENASICA’s Web 

page and updated monthly [6]. 

From 2004 through 2007, SAGARPA directed its State offices (delegations) to inspect, on an 

annual basis, rendering firms that had notified SAGARPA that they were operating or 

previously registered. Incentive to provide notice of operation to SAGARPA came mainly 

from feed manufacturers who wanted to obtain source material only from registered 

rendering plants. 

Inspections of rendering plants found a very high level of compliance. In 2007, SAGARPA 

reported two minor infractions in two rendering plants located in Yucatán and Guanajuato. 

The infractions consisted of inadequate documentation describing the species used in the 
9 

source material for the rendered product [7]. Both establishments were subsequently reinspected and found to be in compliance. 

2. Feed mills 

SAGARPA began registering feed mills in 1993. In addition to the routine oversight 

provided by veterinary consultants, a feed mill inspection program was initiated in 2004. 

Under this program, the veterinary consultants conducted inspections using inspection 

checklists [8] to verify that feed mills were operating in compliance with NOM 061. 

Similar to its oversight of rendering plants, in 2005 SAGARPA began applying its 

verification and registration program to all firms involved in the manufacturing of chemicals, 

pharmaceuticals, biologics, and feed products for animal use or animal consumption. All 

companies involved in the manufacture, import, and distribution of veterinary products were 

also required to be registered and inspected. As of the end of 2008, approximately 2,300 

establishments were registered [8]; of these, about 500 manufacture animal feeds or feed 

ingredients, with approximately 200 feed mills producing finished feed for ruminant and 

nonruminant animals [8]. 

IV. Livestock Industry and Husbandry Practices 

In addition to evaluating Mexico’s legal authorities and their enforcement of the ruminant 

feed ban, the APHIS–FDA team also sought to understand their significance in the context of 

the country’s agricultural and social practices. Much of this information was obtained from 

the dossier submitted to the OIE by SAGARPA [2] 

In 2008, Mexico’s total cattle inventory was estimated at 35 million animals, the majority of 

which is for beef production. Mexico exports approximately 1.1 million head annually, 

mostly to the United States. The total number of cattle consigned annually in Mexico for 

domestic slaughter is around 6.7 million head, and the calf crop is estimated at 8.2 million 

head. The beginning beef cow inventory in 2008 was estimated at 11.9 million head and the 

beginning stock of dairy cows was estimated at 2.5 million head. The Mexican domestic 

cattle inventories for 2009 are expected to increase due to reductions in cattle exports to the 

United States and the higher prices of red meat in Mexico. Cattle slaughter figures for 2009 

are forecast to increase at approximately the same rate as in 2008 (2 percent) because 

increasing feed costs are forcing feedlot operators to reduce inventories [9]. 

As described in SAGARPA’s dossier to the OIE, most Mexican cattle are raised on either 

dairy farms or beef cattle operations. The national dairy herd is divided into several different 

and distinct sectors: specialized or technically developed dairies, approximately 17 percent of 

operations; semi-specialized, 15 percent; double purpose (for beef and milk), 60 percent; and 

family or backyard units, 8 percent. Both purebred and mixed breed cattle can be found 

within any of the categories. Dairy production units operate either as separate entities or as 

groups of producers such as Lala or Alpura, which pool the dairy production of many 

producers in the Lagunera Region and in the Altiplano of the Mexican Republic. Typically, a 
10 

single feed mill distributes balanced feed to each of the respective group’s members. Feed 

mills serving the dairy sector largely discontinued the use of rendered animal proteins before 

2004. 

For beef cattle, Mexico’s production model does not differ greatly from what is done in the 

United States. Typically, cattle either graze or are fed in confinement, although some 

producers may use parts of both production models. Operations that primarily graze (such as 

cow-calf operations) usually provide some supplemental feed, such as salt or minerals. Cattle 

fed in confinement (e.g., in feedlots) are usually fed a mixed, balanced feed. The average age 

and weight at slaughter varies according to rearing system. Slaughter tends to occur at 

approximately 3 years on extensive pasture, 2 years on semi-intensive, 1.3 years on intensive 

fattening, 6 to 7 years for dairy cows, and 10 years for breeding beef cows [10]. The review 

team visited two feedlots, one in the State of Aguascalientes that handles approximately 2000 

animals at a time and the other in the State of Querato that handles approximately 5500 

animals at a time. On these and other feedlots in Mexico, fattening typically occurs over a 

period of 90 to 100 days. The ration fed by the feedlots may contain a wide variety of 

ingredients, which are primarily of plant origin. 

The nutritional requirements of dairy and beef cattle differ, and the nutritional needs of each 

vary by age and stage of production. Animal-source proteins may be useful in the rations of 

dairy cattle to balance specific nutrients (such as lysine and other amino acids, calcium, and 

phosphorus) and supplement protein intake. However, a variety of plant proteins and animal 

protein alternatives from nonprohibited sources are available to Mexican producers including 

processed corn, sorghum, oats, soy products, fish meal, porcine blood meal, and feather meal. 

Furthermore, brain and spinal cord from slaughtered cattle are unlikely to end up in animal 

feed because they are marketed profitably for human consumption. 

V. Rendering and Feed Industries 

Globally, the rendering industry plays an important role in the risk of recycling BSE 

infectivity. Although the inclusion of rendered ruminant protein into bovine feed is thought 

to have caused the initial emergence and amplification of BSE, the rendering process can 

also mitigate the likelihood of further spread or amplification. First, rendering processes can, 

to varying extents, reduce infectivity of the BSE agent. Second, rendering may also serve as 

an additional opportunity for the redirection of ruminant protein away from cattle feeds. Such 

redirection can also be performed by the feed industry. To provide context for these potential 

sources of risk mitigation beyond that required by regulation, in this section we describe 

some characteristics of the Mexican rendering and feed manufacturing industries. 

1. The Rendering Industry 

As explain ealier, in Mexico, rendering plants are classified into two types: type 1 rendering 

plants, which process and handle materials from pigs, horses, poultry or other nonruminant 

species as well as hides and ruminant byproducts obtained from tanneries (or their mixture)3

, 

 

3 Ruminant hides and ruminant byproducts of tanneries are not considered to pose a BSE risk. 
11 

and type 2 rendering plants, which handle ruminant materials or any ruminant tissues that are 

mixed with tissues of pigs, horses, or other avian species, as well as hides and ruminant 

byproducts from tanneries (or their mixture) [2, 11]. 

Rendering plants are also categorized as captive (integrated) and noncaptive (independent), 

depending on their source of raw materials. Captive rendering plants receive raw material 

from slaughter or other processing facilities, generally within the same company. This type 

of enterprise processes raw materials that have been inspected by Federal or State 

veterinarians. Cattle slaughtered in the affiliated slaughterhouses can be sourced from 

livestock production units located far away from the slaughterhouse, or even in other States, 

depending on market fluctuations and commerce. In general, poultry facilities usually have 

their own rendering plants. Other specialized rendering plants process tannery or leather 

byproducts; these are usually located with shoe industry manufacturers. 

Noncaptive (independent) rendering plants collect raw materials from slaughterhouses and 

other businesses (such as butcher shops, restaurants, institutions, supermarkets, and other 

places where meat is processed) that do not have their own rendering facilities. Collected 

materials include animal fat, bones, hooves, and horns. In addition, some noncaptive 

rendering plants may render animals that died on-farm or were condemned in 

slaughterhouses. 

The largest numbers of rendering plants are located in the States of Mexico and Jalisco, while 

other States average two plants each [2]. Most of the raw materials used in rendering plants 

originate from slaughterhouses, packers, or butchers. The majority of type 2 plants process 

bone and uncooked tallow; very little nervous tissue (brain and spinal cord) is processed 

since it is profitably sold for human consumption [2, 7, 12]. Ninety per cent of the raw 

materials are derived from cattle while the rest comes mainly from swine; poultry and horse 

materials are rarely rendered. Ovine material is not used [2, 11]. 

Animals (particularly range cattle) that die on the farm usually are not sent for rendering but 

remain on the farm for disposal. In addition, instead of being disposed of, some animals that 

are ill can be slaughtered on an emergency basis on the farm and used for human 

consumption. Range cattle mortality varies between 2 to 3 percent in most areas of Mexico. 

The main causes of mortality in range cattle are plant intoxication, anaplasmosis, pneumonia, 

and rabies. Dead animals may remain in the pastures until they are eaten by buzzards and 

other scavengers, or they may be buried if they are very close to a community or a house. 

Disposing of dead cattle on the farm is common in the States of Colima, Baja California Sur, 

and Guerrero; in the Southeast region (the Huasteca that comprises some municipalities of 

the State Veracruz, Tamaulipas, San Luis Potosi, and Hidalgo); and in the desert zone of the 

North of the country such as Sinaloa, Zacatecas, Sonora, Chihuahua, Nuevo Leon, and 

Coahuila. 

In dairy cattle production zones with a high density of animals (such as those shared by the 

State of Aguascalientes and Jalisco in Altos Region, Tizayuca, Hidalgo; Rincón de Romos, 

Queretaro; Zumpango, Estado de Mexico; Delicias and Cd. Cuahtemoc, Chihuahua; Mexicali 

in Baja California and the Lagunera Region in the States of Coahuila and Durango), 
12 

mortality ranges between 2 and 5 percent annually. Deaths are primarily due to intoxication, 

metabolic disease, pneumonia, reproductive problems, and tuberculosis. Dead dairy cattle are 

rarely rendered and instead are buried, incinerated, or slaughtered under emergency 

inspection for human consumption. 

Most rendering plants in Mexico use the batch cooker rendering system consisting of a 

horizontal vapor cooker with a stirrer. Such systems operate under atmospheric pressure. The 

cooked batch follows a repetitive cycle where a cooker is loaded with the appropriate amount 

of raw material then cooked under specific, controlled conditions. Each batch contains from 

3,000 to 4,000 kg of raw material that has been ground to a 2.5-cm particle size. Cooking 

temperatures range from 80 to 160°C, with an average of 120°C. Processing times range 

from 15 minutes to 8 hours, with an average of 2.5 hours [2]. 

Experimental studies performed on similar systems elsewhere have shown that batch 

rendering leads to a greater than 3 log reduction in BSE infectivity [13, 14]. A smaller 

number of Mexican type 2 renderers use a continuous system. These systems typically reduce 

BSE infectivity by 1 to 2 logs, depending on whether fat is added during the process [13, 14]. 

At the time of Mexico’s submission to the OIE, there were 57 SENASICA-registered 

rendering plants, of which 19 were classified as type 1 and 38 were classified as type 2. As of 

October 2008, these numbers increased to 65 registered rendering plants, of which 20 are 

type 1 and 45 are type 2 [7]. 

2. The Feed Industry 

Mexico is ranked among the largest producers of balanced feed in the world. Domestic 

producers dominate the Mexican balanced feed market. The 2008 total production of 

compound feed (mixed feed manufactured by combining multiple ingredients) was estimated 

at 26.2 million metric tons (MT), approximately 16.6 million MT produced by integrated 

firms4

 and 9.6 million MT by commercial manufacturers. 

Most of the raw material used for producing prepared feed is of plant origin. Vitamins, 

minerals, and oils make up most of the rest of the ingredients. Common protein meals 

contain, among other products, soy meal, feather meal, blood, and MBM from various animal 

species [2, 11]. 

The site visit review team visited several feed manufacturing facilities, including large, 

small, integrated, and commercial facilities. Most of these firms produced feed for all major 

pet food and livestock species and, as stated above, most use principally plant origin material 

(corn, sorghum, oat, soy, etc.). Most companies either do not use animal protein or only use 

fish or equine meals. Most of the firms used their own trucks for making deliveries and 

occasionally for hauling incoming ingredients. At the facilities visited, the team observed that 

procedures were in place to ensure proper cleaning between shipments. Regardless of firm 

 

4 Integrated firms produce their own feed for animals that they typically breed, raise, and slaughter; they also market the 

resulting meat. 
13 

size, most feed was bagged prior to delivery, with only a small amount of feed distributed in 

bulk. 

The site visit team observed that, in general, the feed manufacturing sector in Mexico has 

access to the same manufacturing technologies and ingredients that are used by feed 

manufacturers in the United States. The team found that feed mill management and 

production personnel were trained in animal nutrition and feed manufacturing. Given that the 

cattle, swine, and poultry production sectors follow production models very similar to those 

used in the United States, the feed manufacturing and distribution system is comparable to 

the U.S. model. However, the team observed a few differences: (1) farms and ranches tend to 

have smaller numbers of animals than operations in the United States; (2) feed manufacturers 

in Mexico tend to use flat storage (storage in piles inside, on the floor of a warehouse) for 

ingredients more commonly than in the United States, where bin storage is more common; 

and (3) most commercial feed in Mexico is bagged prior to distribution and not stored or 

transported in bulk. The fact that most feed is bagged suggests a lower risk of crosscontamination of equipment with prohibited material during transport and on-farm storage. 

Moreover, the storage of materials on the warehouse floor can allow more thorough cleaning 

between batches than can typically be performed for bins. 

Conclusion: Date of Effective Enforcement of Feed Ban 

In May 2008, the OIE announced that it had categorized Mexico’s BSE status as controlled 

risk, based on the committee’s recommendation. This decision was based on several factors, 

including the level of surveillance, the absence of detected cases, and the demonstration 

“through an appropriate level of control and audit that neither meat and bone meal nor 

greaves derived from ruminants has been fed to ruminants” [12]. Therefore, the OIE 

determined that Mexico has an effectively enforced feed ban that prohibits the use of 

ruminant-origin MBM and greaves in feed for ruminants. Proposed changes to regulations 

would allow APHIS to recognize Mexico’s controlled BSE risk status. 

In determining that a country has a controlled BSE risk status, the OIE concludes that the 

country has an effectively enforced feed ban in place but does not determine the date on 

which the feed ban was effectively enforced. For Mexico, APHIS determined that date using 

information provided by Mexico and corroborated by the site visit team. The information 

relates to the underlying regulations and evidence of their enforcement as well as to the 

context provided by Mexico’s cultural practices, animal husbandry, and the feed and 

rendering industries. 

We report above in Section III that Mexico instituted regulations regarding a ruminant feed 

ban in 2000 and 2001. NOM 061, published in 2000, prohibited the use of ruminant-origin 

MBM in feed for ruminants. NOM 060, published in 2001, placed specific requirements 

related to BSE on rendering plants. 

Initially, compliance with these regulations was enforced by SAGARPA-certified 

verification unit veterinarians employed by rendering plants and feed mills. In the following 

years, Mexico continued to enhance the implementation and enforcement of its feed ban. The 
14 

most recent enhancement was the reorganization of the DRPC and the creation of the 

Department of Regulation of Establishments. This reorganization and the support from 

Mexico’s accreditation body for verifying rendering plants provided additional opportunities 

to monitor and enforce the ruminant feed ban. 

In addition to information regarding Mexico’s legal requirements for a ruminant feed ban and 

their enforcement, the review team also considered Mexico’s cultural and agricultural 

practices. Practices such as the consumption of SRMs by humans, use of the batch method of 

rendering, domestic production of feed, and bagging of feed act individually and in concert to 

reduce the likelihood of any BSE infectivity circulating in the ruminant population. 

Therefore, while an effectively enforced feed ban is still necessary, its importance to the 

actual BSE risk in Mexico is less than that for other controlled risk country that has a history 

of BSE or does not demonstrate these mitigating practices. 

As described above, the level of enforcement of Mexico’s ruminant feed ban has increased 

over time. The date when the feed ban became effectively enforced is difficult to determine 

precisely, especially given the low BSE risk background in which the regulations are applied. 

However, APHIS considers that by the time Mexico prepared and submitted its dossier to the 

OIE (in December 2007), SAGARPA was able to demonstrate through an appropriate level 

of control and audit that neither MBM nor greaves were fed to ruminants. Therefore, APHIS 

is establishing the effective date as November 30, 2007. 

While this date of effective enforcement is based on the evidence provided to the OIE by 

Mexico and gathered during the site visit conducted by APHIS and FDA, it does not reflect 

the relative BSE risk of live animals imported into the United States from Mexico. Rather, it 

is one step in aligning APHIS’ proposed BSE regulation with OIE guidelines. As stated 

above, based on Mexico’s import history and production and consumption practices, 

Mexico’s cattle have consistently had an acceptably low risk of exposure to BSE. 

References 

1. OIE. Terrestrial Animal Health Code, Chapter 11.6. Available at http://www.oie.int/eng/ 

normes/mcode/en_chapitre_1.11.6.htm#rubrique_encephalopathie_spongiforme_bovine. 

2. SAGARPA. Recognition of the Sanitary Situation of Mexico with Respect to Bovine 

Spongiform Encephalopathy (BSE): Request. 2007. 

3. OIE. Final Report of the 76th General Session of the OIE, 25–30 May 2008. Available at 

http://www.oie.int/downld/SG/2008/A_RF_2008_webpub.pdf. 

4. SAGARPA. Example of official letters sent to rendering plants informing them of the need 

to comply with NOM 060. 2003. 

5. SENASICA. http://148.243.71.63/default.asp?id=916. 

6. SAGARPA. Additional information requested by APHIS. 2008. 

7. SAGARPA. Documentation regarding rendering plant infractions in 2007. 2007. 

8. SAGARPA. Checklist used to evaluate compliance with feed regulations. 
15 

9. USDA Foreign Agriculture Service. Global Agriculture Information Network (GAIN) 

Mexico Livestock and Products Annual Report. 2008 

10. European Food Safety Authority. Scientific Report of the European Food Safety 

Authority on the Assessment of the Geographical BSE Risk of Mexico (July 2004). 

Available at http://www.efsa.europa.eu/EFSA/efsa_locale1178620753812_1211902594133.htm 

11. SAGARPA. Mexican Enforcement of the Feed Ban. 2007. 

12. OIE. OIE Ad Hoc Group for the Evaluation of Country Status for Bovine Spongiform 

Encephalopathy in Accordance with the Terrestrial Animal Health Code, p. 44-46. 

February 2008. 

13. Taylor DM, Woodgate SJ, Fleetwood AJ, and Cawthorne RJG. Effect of rendering 

procedures on the scrapie agent. 1997. Vet Rec 141(25): p. 643-649. 

14. Taylor DM, Woodgate S, Atkinson MJ. Inactivation of the bovine spongiform 

encephalopathy agent by rendering procedures. 1995. Vet Rec 137(24): p. 605-10.